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The Home Office and The FA have announced a number of changes to the Governing Body Endorsement (GBE) criteria for international footballers in the UK. The changes, which came into effect from the opening of the June transfer window on 14th June 2023, are designed to provide additional access to exceptional international talent which falls outside the current GBE criteria.
GBEs are a requirement for international footballers who want to play in the UK. They are issued by The FA and are based on a number of factors, including the player's international caps, their club, and international goalscoring record, and their age. Key determining factors include the ranking of the player’s national team and the standard of the league they are playing in.
The main change to the criteria is the introduction of a new Elite Significant Contribution (ESC) category. This category allows clubs to sign players who do not meet the standard GBE criteria, but who are considered to be of exceptional talent.
To qualify for the ESC category, players must meet at least one of the following criteria:
Importantly, the continental and domestic competitions only apply to band 1–5 leagues. So whilst leagues like the South Korean K League, the Chilean Primera División and the Uruguayan Primera División make the cut, the top divisions in Finland, Canada, and Peru don’t qualify.
Premier League and Championship clubs will be able to sign a maximum of four players who fall under the ESC category, whilst League One and League Two clubs will be able to sign a maximum of two.
However, the number of players a club will be able to sign will be proportional to the number of English Qualified Players (EQPs) they play throughout the season. Each club will start with at least 2 slots for the 23/24 season, however if EQPs do not get enough game time throughout the season the club’s allowance will be reduced for the following season.
There are a significant number of caveats that apply to how the EQP minutes are calculated, for example the four highest and lowest EQP matches are struck from the calculation and there is an allowance for unavailability of EQPs. However, data on EQP minutes over the past three seasons shows that it’s highly likely that more than half of Premiership clubs will see a reduction in their ESC quota for the 24/25 season. The picture is very different in the Championship, where it’s likely that only a couple of teams will see a reduction.
As such, it’s going to be important for Premier League clubs in particular to transition their ESC signings into the standard GBE criteria to make sure they are keeping their quota available for new signings in the future.
Once an ESC player has completed their first year in the UK, they can transition to the standard GBE criteria if they fulfil either the auto pass criteria or meet the 15 point threshold. This means that the player can remain in the country, and the club regains the use of that ESC slot.
Importantly, there is another route to transitioning. If an ESC player plays in 25% or more of their club's EQP matches or if they play the required percentage of available minutes, then they can also transition to the standard GBE criteria. This is a critical aspect of the rule changes and is a very good reason for making use of the ESC quota. It allows clubs to recruit international talent on an ongoing basis that it would not otherwise be able to do so. Lower league clubs in particular will benefit from this as they are less likely to be able to attract players who meet the standard GBE criteria, so whilst this is not quite a return to freedom of movement it’s a big concession nevertheless.
If we judge him on his time at Norwich City, it’s fair to say that Teemu Pukki is a great Championship, and extremely competent Premier League player. Being Finnish, when Norwich signed Pukki in 2018 there were no visa issues to consider as we were still in the EU at that time, however, if Norwich had tried to sign Pukki last year they would not have been able to, as he did not meet the auto pass or 15 point threshold.
Teemu Pukki’s success at Norwich is a perfect example of how teams can use their ESC quota to enrich their squads. Through careful scouting and analysis, clubs can start to identify talent in leagues around the world that they have never been able to consider before. There is obviously the attraction of the European leagues, however being able to scout and attract talent from more South American and Asian leagues than ever before unlocks the prospect of more future global stars applying their craft in English leagues.
The changes to the GBE criteria are a positive step for the English football landscape. They will give clubs the opportunity to sign more talented players from around the world, which will help to improve the quality of the English game. The changes also present an interesting challenge to clubs around ensuring that they are offering enough playing time to EQPs over the coming seasons. If you can show that you are encouraging the development of EQPs then you will be rewarded with additional ESC slots, however if you are too reliant on overseas players then you will have your ESC quota reduced.
It will be interesting to see how the changes to the GBE criteria impact the English football landscape in the years to come. However, there is no doubt that they are a positive step for the game.
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Consistent with our policy when giving comment and advice on a non-specific basis, we cannot assume legal responsibility for the accuracy of any particular statement. In the case of specific problems we recommend that professional advice be sought.
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If you have any questions relating to this article or have any legal disputes you would like to discuss, please contact the Immigration team on
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